This book provides a practical and technical guide to tax treatment and transfer pricing of intangibles such as patents, knowhow, copyrights, trademarks, exploitation rights etc. Starting with the issues involved in identification and taxation of transactions in intangibles and rights, the book goes on to discuss the nuances of finding the arm’s length range of royalty rates, IP transfer, Hard to Value Intangibles, marketing intangibles, corporate guarantee, and value at risk. There is a dearth of literature on the practical aspects of income tax and transfer pricing practice; this book seeks to rectify that. The book discusses methods and models of benchmarking of intangibles, and goes on to demonstrate – step by step – how these methods and models can be used to arrive at the arm’s length standard. The nuances arising from assessment and litigation trends have also been highlighted. Other issues covered in the book are taxation of digital economy, tax treatment of cryptocurrencies, and taxation of intangibles under GST.

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Product description

Product Description

This book provides a practical and technical guide to tax treatment and transfer pricing of intangibles such as patents, knowhow, copyrights, trademarks, exploitation rights etc. Starting with the issues involved in identification and taxation of transactions in intangibles and rights, the book goes on to discuss the nuances of finding the arm’s length range of royalty rates, IP transfer, Hard to Value Intangibles, marketing intangibles, corporate guarantee, and value at risk. There is a dearth of literature on the practical aspects of income tax and transfer pricing practice; this book seeks to rectify that. The book discusses methods and models of benchmarking of intangibles, and goes on to demonstrate – step by step – how these methods and models can be used to arrive at the arm’s length standard. The nuances arising from assessment and litigation trends have also been highlighted. Other issues covered in the book are taxation of digital economy, tax treatment of cryptocurrencies, and taxation of intangibles under GST.

About the Author

Smarak Swain graduated in Electrical Engineering from Indian Institute of Technology, Kharagpur in 2006, and joined the Indian Revenue Service (IRS) in 2008. He has also done Masters in Taxation and Business Laws (MTBL) from NALSAR University, Hyderabad. In the income tax department, he has experience in the fields of corporate and business assessments, tax administration of charitable and religious trusts, investigation, and transfer pricing. He has authored three works of non-fiction and a science fiction. International law, financial forensics, and financial modeling are his primary areas of interest.